UnifiedOnline Inc fka UOIP

[papa p]

While defenses to paying Ms. Leane exist because she signed the ASA (D.I. 6, Ex. C) on
which the Arbitration Award is based on behalf of both IPNAV and Chanbond, allegedly without
obtaining Plaintiff’s consent to this interested transaction and then fraudulently failed to disclose
her self-interested execution of the ASA when she sold Chanbond to its current owner, the
Arbitration Award presents an impediment to Plaintiff’s ability to succeed on the merits.
Because the question of whether the Arbitration Award is enforceable must be decided prior to
any further distributions to Plaintiff, Plaintiff cannot demonstrate a reasonable probability of
success on the merits. As such, the Motion should be denied.